Submissions

Transport Canada’s Grade Crossings Regulations do not explicitly state who is responsible for bearing the financial burden associated with the newly mandated safety upgrades. In the past, these upgrades and ongoing maintenance have always been performed by the railways, at the railways expense. Our concern is that in cases where pre-existing agreements are not already in place, the railways are now taking unilateral action to shift the cost burden for maintenance and upgrades of private crossings onto farmers, where they traditionally have done so, under threat of removing an existing and active private railway crossing altogether. Furthermore, we are hearing from our members of cases where farmers have received 30-day notices to close their crossings or that their crossing was removed by a railway without any notice.

The industry supports the safe handling of anhydrous ammonia through the Code of Practice. But, at present, there is no evidence suggesting that change to the current regulations is warranted, or that forcing farmers to have and maintain an expensive ERAP will reduce the number of incidents involving anhydrous ammonia.

Given theses concerns, we request that Transport Canada rescind their proposed amendments to section 1.24 of Transportation of Dangerous Goods Regulations.

While national standards are essential, it is crucial that these standards are adaptable to the diverse conditions across Canada’s provinces and territories. Housing challenges vary significantly depending on regional contexts—for instance, seasonal housing shortages in British Columbia, unique conditions in Quebec’s rural areas, and the distinct needs of operations in Nova Scotia. These regional differences must be taken into account to ensure the standards are both effective and feasible.

The CFA uses the data from the FMS to inform its reporting and messaging on the sustainability, productivity, and innovation within the Canadian agricultural sector. The data allows us to quantify the impact of best practices with validated information to inform policy positions, and advocate for continued development of a resilient agriculture sector in Canada.

The pending disruption of Canada’s two national rail carriers, CN and CPKC, poses a significant risk to our industries and the broader Canadian economy and even our natural environment. Not only does a prolonged work stoppage threaten our international reputation, but places upward pressure on inflation and the cost of consumer goods thereby threatening our national food security. For this reason, we are urging the Minister to consider using section 107 of the Canada Labour Code to direct the CIRB to help parties reach an agreement under binding arbitration.

The simultaneous labour dispute between CN and CPKC and the Teamsters Canada Rail Conference (TCRC) union will have a devastating impact on the transportation of goods into this fall harvest. In addition to the shipment of agricultural products to market, farmers in many parts of Canada require a steady and stable supply of propane for grain drying, greenhouse production and heating and cooling of livestock barns. In fact, I understand that CN has already stopped shipments of “hazardous items” including fertilizers, ahead of a potential work stoppage, and at a time when shipments were being ramped up for next spring. The inability to
access these products at critical stages of production could result in food loss due to spoilage, acute animal welfare concerns due to a backlog of livestock slaughterhouse capacity, and the inability to maintain business continuity due to a lack of essential inputs.

The potential simultaneous disruption of Canada’s two national rail carriers, CN and CPKC, poses a significant risk to our industries and the broader Canadian economy and even our natural environment. Not only does a prolonged work stoppage threaten our international reputation, but places upward pressure on inflation and the cost of consumer goods thereby threatening our national food security.

On behalf of the Grain Growers of Canada (GGC), Canadian Canola Growers Association (CCGA) and the Canadian Federation of Agriculture (CFA).

It is our view that the federal government has a clear role in establishing a legislative framework that strikes a measured and appropriate balance with the intent to create a competitive market for equipment repair that will allow farmers the choice to safely conduct all repairs themselves, through a qualified third party, or through OEM dealerships. Changes could also encourage new business opportunities for Canadians by creating more repair shops in rural communities. Supporting a legislative framework that supports the interoperability of farm equipment will also help competitiveness, drive innovation, and provide cost-effective options for farmers. We continue to be supportive of Bills C-244 and C-294 currently in the Senate and how they can contribute towards fostering right to repair framework for agricultural machinery in Canada.

A joint letter with many stakeholders including the Canadian Chamber of Commerce, urging the government to intervene and do everything necessary to avert a disruption in Canada’s Class I railways.

The last few years have been challenging for potato growers in Canada, following the restrictions on PEI potato exports to the USA in 2021. Although this decision has been revoked and exports have resumed, these decisions have caused irrevocable harm to the “PEI potato” brand and seed exports from PEI to other Canadian provinces is still prohibited. CFA further recommends that CFIA collaborates with the potato growers’ organizations on the development of compensation regulations that include loss of future potato revenue and devaluation of farmland due to declassification of farmland.

At a high level, these comments recommended:

– Eliminating protectionist measure and non-tariff trade barriers that limit market access for Canadian agriculture and agri-food products.
– Developing new measures so that imported products have the same standards and safety measures as domestic products.
– Remaining committed to not granting new market access to supply-managed products.
– Have Global Affairs Canada (GAC) adopt a transparent approach as it moves through the next steps of the process.

It is important for young people to learn about the environment, their place in it, and how their actions, individually and collectively, impact it. However, CFA believes it is also crucial for them to learn about how Canadian farmers are leading the charge in sustainable agriculture, about how Canadian farmers are spearheading the solutions instead of being part of the problem when it comes to environmental sustainability.